Subject: Wilderness Inventory Comments; Forest Plan Revision

Elkhorns Wilderness Evaluation Inventory

“The Elkhorns GA encompasses the Elkhorn Mountains in Broadwater and Jefferson counties and includes the small mining town of Elkhorn. The nearest large population center is Helena, Montana. Many smaller communities also have intimate relationships with the GA: Montana City, Clancy, Alhambra, Jefferson City, Boulder, Radersburg, Townsend, Winston, and East Helena.” (HLCNF Draft Desired Conditions, at 60 (Nov. 2015).)

“The economy of [Broadwater] county has traditionally been based upon on agriculture and logging. Currently both of these industries are in a slump and the county’s economy is depressed. . . . The communities [within Broadwater County] are looking more towards recreation related industries to provide additional income to the communities.” (HLCNF Roads Analysis Report, at 18 (2004) (emphasis added).) “Dependence upon wildlands for income [in Jefferson County] dropped to 33.25% and recreation and viewshed have become more economically important uses of National Forest than timber extraction. Mining operations have shrunk and timber harvest has declined to almost nothing. [Jefferson] county is looking more towards recreation and tourism as possibilities to expand their economy.” Id. (emphasis added).
The history of the Elkhorns status of wilderness and inclusion as a Wildlife Management Unit was summarized by the HLCNF’s Forest Plan Assessment:
The Montana Wilderness Study Act (Public Law 95-150) identified the Elkhorn Mountain range as needing “additional study” for its potential inclusion in the National Wilderness Preservation System. Before the Montana Wilderness Study Act was finalized in 1977, and after considerable public input and hearings, Congressman John Melcher separated the Elkhorns out of the act and introduced similar but separate legislation that established an individual wilderness study area for the Elkhorns. By enacting Public Law 94-557 in 1976, Congress directed the Forest Service to evaluate approximately 77,346 acres of the Elkhorns for possible inclusion in the National Wilderness Preservation System.
Between 1977 and 1981, the Elkhorns Wilderness Study Area was analyzed to determine its inclusion into the National Wilderness Preservation System. There was high public interest in the analysis that was conducted, and much criticism from both the conservation and multiple use communities. Finally, on November 24, 1981, chief of the Forest Service, R. Max Peterson, signed a record of decision based on the analysis in the Final Environmental Impact Statement. The record of decision states, “It is my decision to recommend that the Elkhorn Wilderness Study Area not be designated wilderness. Direction will be developed for the Helena and Deerlodge Forest Plans to establish a management unit which emphasizes the very high wildlife values.” All 160,000 acres of Forest System lands within the Elkhorn Mountain Range were administratively designated as a wildlife management unit.
In 1982, President Reagan transmitted to congress his concurrence with the Secretary of Agriculture (John Block) that the Elkhorns were not suitable for inclusion in the National Wilderness Preservation System. Congress had four years to consider that recommendation and act on it, and if not, the recommendation would be automatically implemented. During that 4-year period, the Forest Service was to continue managing the study area to maintain its wilderness potential. By 1986, in the four years, congress did not act on the President’s recommendation, which automatically implemented the recommendation and released the Forest Service from its mandate to maintain the area under the designation as a wilderness study area.
(HLCNF Forest Plan Assessment, Ch. 8, Existing Designated Areas, at 11 (emphasis added).)
“There are numerous trailheads and dispersed recreation opportunities throughout the Elkhorns, including a number of dispersed nonmotorized trails and primitive camping areas.” (HLCNF Draft Desired Conditions, at 61 (Nov. 2015).) “Recreation in the Elkhorns emphasizes its unique resources including . . . a well-defined and managed transportation system which offers opportunities for both non-motorized and motorized recreational activities.” (HLCNF Forest Plan Amendment No. 15, at 2 (March 6, 2000 (emphasis added).)
One of the stated guidelines for Forest Plan management within the Elkhorns GA is to “Provide specific opportunities to enhance the safety and enjoyment of non-motorized recreational users, including 10-20 miles of marked cross-county ski and mountain bike trails, and permitted wildlife viewing guided trips.” (HLCNF Forest Plan Amendment No. 15, at 12 (March 6, 2000 (emphasis added).) In fact, one of the stated goals for the non-motorized areas within the Elkhorns is to provide “a variety of semi-primitive and primitive nonmotorized recreation opportunities within the context of a healthy, diverse ecosystem.” Id., at 20 (emphasis added). The Forest Service has even produced a mountain biking map of the Elkhorns.
As previously indicated, Helena, Montana – the Elkhorn’s nearest population center – has become a destination for mountain biking over the past decades. For example, in 2013, the Helena Tourism Alliance launched Bike Helena in an effort to brand Helena as a biking destination. See Madison, Helena Makes its Mark as a Mountain-Biking Destination, supra. Helena is also now recognized as a silver-level riding center destination by the IMBA. See id. IMBA’s silver-level designation earned Helena and the HLCNF recognition in mountain-biking magazines, on websites and on top mountain-bike destination lists.
The ever-increasing popularity of mountain biking in general, and specifically in the Helena area, has resulted in growing numbers of mountain bikers flocking to ride HLCNF’s trails. In turn, this has resulted in growing congestion and use on the already existing trails that are open to this semi-primitive nonmotorized ROS class. It is therefore necessary that the surrounding areas – including the Elkhorns – remain open for trail expansion and semi-primitive nonmotorized use in the future. A large percentage of HLCNF lands are currently preserved for their wilderness characteristics due to their wilderness designations. However, were the HLCNF to expand the NWPS by including certain lands within the Elkhorns, such actions would forever prevent and preclude mountain bikers from ever using those lands. Accordingly, I respectfully request that the HLCNF consider these impacts in its evaluation of wilderness inventory areas, and further, that the HLCNF neither carry forward nor include the following areas for NEPA analysis as potential recommendations for inclusion in the NWPS.

1. 
   Elkhorns #1 – Polygon E1
   

1. 
   Existing mountain biking trails within E1
   

I respectfully request that Elkhorns Polygon E1 is not recommended for a wilderness area because of the following roads and trails that would be closed for mountain biking use:

Trail/Road Polygon #

Casey Meadows #343 E1

Pinecrest Trail E1

McClellan Creek Trail #294 E1

S. Fork Crow Creek Trail #277 E1

Crow Creek Trail #424 E1

Beaver Creek #115 E1

Longfellow Park Area #112, 133, 138, 135 E1

Sheep Park #116 E1

2. 
   Areas for mountain bike trail expansion within E1.
   

As a result of the ever-increasing popularity of mountain biking in the Helena area, described supra, there is a corresponding need to relieve congestion on existing trails open to mountain biking. In addition to its existing roads and trails, the E1 Polygon represents an area where semi-primitive nonmotorized trails could be expanded and maintained in the future. Doing so would alleviate some of the pressures on the already existing trails and further support the multi-use management goals required under MUSY and NFMA. However, in the event that the E1 Polygon was recommended for inclusion in the NWPS, such action would forever prevent mountain bikers from using those lands and would similarly prevent “sufficient latitude for periodic adjustments in use to conform to changing needs and conditions.” 16 U.S.C. § 531(a). I therefore respectfully request that the E1 Polygon is not carried forward for NEPA analysis.

3. 
   Wilderness attributes of E1.
   

“The landscapes and the vegetation of the Elkhorn Mountain range have been significantly altered by historic placer and lode mining, free range grazing, and recreation. . . . These influences have had serious and lasting impact on the natural resources of the area[.]” (HLCNF Forest Plan Assessment, Ch. 8, Existing Designated Areas, at 12 (emphasis added).) Polygon E1 is also subjected to regular, low-altitude aircraft traffic flying in and out of the Helena Regional Airport. Because Polygon E1 does not contain sufficient wilderness characteristics, I respectfully request that it is not included for further wilderness evaluation.

2. 
   Elkhorns #3 – Polygon E3
   

1. 
   Existing mountain biking trails within E3
   

I respectfully request that Elkhorns Polygon E3 is not recommended for a wilderness area because of the following roads and trails that would be closed for mountain biking use:

Trail/Road Polygon #

Muskrat Creek Trail #441 / 72 / 111 E3

In its wilderness evaluation, the HLCNF should take into account that the Muskrat Creek Trail is one of the most popular destination mountain bike rides in the state of Montana.

(Muskrat Creek Trail. Photo credit: Jared Steffen.)

(Muskrat Creek Trail. Photo credit: Mike Williamson.)

(Muskrat Creek Trail. Photo credit: Jared Steffen.)

2. 
   Areas for mountain bike trail expansion within E3
   

As a result of the ever-increasing popularity of mountain biking in the Helena area, described supra, there is a corresponding need to relieve congestion on existing trails open to mountain biking. In addition to its existing roads and trails, the E3 Polygon represents an area where semi-primitive nonmotorized trails could be built and maintained in the future. Doing so would alleviate some of the pressures on the already existing trails and further support the multi-use management goals required under MUSY and NFMA. However, in the event that the E3 Polygon was recommended for inclusion in the NWPS, such action would forever prevent mountain bikers from using those lands and would similarly prevent “sufficient latitude for periodic adjustments in use to conform to changing needs and conditions.” 16 U.S.C. § 531(a). I therefore respectfully request that the E1 Polygon is not carried forward for NEPA analysis.

3. 
   Wilderness attributes of E3
   

“The landscapes and the vegetation of the Elkhorn Mountain range have been significantly altered by historic placer and lode mining, free range grazing, and recreation. . . . These influences have had serious and lasting impact on the natural resources of the area[.]” (HLCNF Forest Plan Assessment, Ch. 8, Existing Designated Areas, at 12 (emphasis added).)

Further, Polygon E3 is surrounded by numerous 4WD tracks and roads also exist in this area, which extend from the town of Elkhorn. The northern and much of the eastern end of Polygon E3 are bordered by a 4WD track/road as well. The western end is all private land, and further, Polygon E3 is approximately 2.5 miles from Interstate 15. As such, opportunities for solitude will likely be difficult in this area. Further, Polygon E3 is subjected to regular, low-altitude aircraft traffic flying in and out of the Helena Regional Airport.
Because Polygon E3 does not contain sufficient wilderness characteristics, I respectfully request that it is not included for further wilderness evaluation.

2.